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No. TBD Issue SC&A Draft Finding NIOSH Response

1 0015-5 (Occupational

Internal Dose)

IN ABEYANCE

Activity values provided for

Tc-99 in reactor tails

understated by several orders

of magnitude.

The TBD provides activity values for 

TRU elements and Tc-99 in reactor tails 

processed at PORTS; however, values 

cited for Tc-99 were understated by 

several orders of magnitude.

The consistent error in Tc-99 values in Table 5.1.2.6-3 was 

confirmed. It should be noted that the yearly values listed in 

Table 5.1.2.6-3 are typically not used to reconstruct a 

Portsmouth worker’s dose; rather, the facility-specific TRU 

and Tc-99 activity fractions provided in Table 5.1.2.6-4 are 

used to calculate RU contaminant intakes and/or intake rates 

based on the calculated uranium intakes and/or intake rates 

and subsequent worker doses. The Recycled uranium 

contaminant activity fractions are under review at this time. 

If required, Table 5.1.2.6-4 will be revised. If Table 5.1.2.6-

3 is retained in the revised TBD, the Tc-99 values will be 

corrected.

SC&A Response (April 2011): Agree that in the context of inaccurate Table 5.1.2.6-3 values for Tc-99, “...information collected since the issuance of this 

document [ORAU-TKBS-0015-5] will be reviewed and the recycled uranium components will be revised as necessary.” (However, this statement is not a 

definitive commitment to revise this table; i.e., judgment will be made at some point in the future).

July 2011 update: In abeyance, pending completion of the recycled uranium review.

Updated DCAS Response: In order to ensure that claimant-favorable activity fractions for recycled uranium contaminants are applied, the highest isotopic 

concentration values recorded during the CIP/CUP period are going to be applied for all years, unless the values based on 1990’s air sampling data are larger. 

Some of the values from the CIP/CUP era, particularly those for Tc-99, exceed the current TBD values derived from the 1990’s air sampling data by a couple 

orders of magnitude. In addition, separate higher values have been calculated for the oxide conversion plant based on the results of filter ash sampling mentioned 

on page 39 of the DOE Portsmouth Mass Balance Report (reference SRDB ID 10916). The facility-specific activity fractions for the assignment of recycled 

uranium contaminants are being revised where appropriate and incorporated into the Internal Dose TBD.

2 0015-5

CLOSED

Inconsistent bioassay

protocols employed that

significantly affect

interpretation of urine

bioassay data.

Interpretation of urinalysis data includes 

variables such as the time at which the 

urine sample is collected relative to the 

worker’s most recent exposure; that 

critical time interval apparently changed 

over time and it is not clear what 

specific protocol was in place at certain 

times.

Sampling dates are provided with bioassay records which are 

to be used rather than an assumed bioassay date. NIOSH 

assesses two types of intakes: intakes from positive results 

and missed intakes from negative results. Missed intake is 

assigned based on a theoretical assumption of a continuous 

intake that was not detected on the date(s) of sampling; in 

this situation (no detectable intake) additional detail of 

monitoring protocol are not needed because a continuous 

intake is assumed up to the limit of detection, unless other 

information indicates the individual had no potential for 

exposure.
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No. TBD Issue SC&A Draft Finding NIOSH Response

If a positive bioassay result(s) is in the records, the DR must 

consider all available information, including, but not limited 

to, individual records, information provided in the TBD, and 

the actual dates of bioassay collection. Thus, an intake based 

on a positive bioassay is case-specific based on all available 

data.

SC&A Response (April 2011): Agree.

July 2011 update: The Work Group also acknowledged NIOSH’s response at the July 6, 2011, Work Group meeting on the question of sampling times in the 

preceding discussion at the meeting of Paducah review issue #15. Work Group closed this issue at its July 6, 2011 meeting.

3 0015-5

IN ABEYANCE

Current guidance for 

estimating internal exposure to 

recycled uranium 

contaminants is unachievable

and/or inappropriate.

Guidance is considered “unachievable” 

because TBD guidance relies upon 

source term data that may not exist, e.g., 

filter ash, cascade deposits, cylinder 

heels, and pond sludges. 

“Inappropriate” is a reference to the use 

of general air sample data collected in 

the 1990s, that would be backextrapolated to earlier years with 

different processes, facilities, and 

radiological conditions.

The Recycled uranium contaminant issue is under review at 

this time. Until the current evaluation is complete, it is not 

possible to make a determination of whether the TBD 

guidance is indeed unachievable. 

SC&A Response (April 2011): In abeyance. NIOSH has not stated agreement or disagreement with the issue as stated; only a commitment to review 

“information collected since issuance of this document...” [ORAU-TKBS-0015-5], which appears to be a standardized response.

July 2011 update: In abeyance, pending completion of the recycled uranium review.

Updated DCAS Response: In order to ensure that claimant-favorable activity fractions for recycled uranium contaminants are applied, the highest isotopic 

concentration values recorded during the CIP/CUP period are going to be applied for all years, unless the values based on 1990’s air sampling data are larger. 

Some of the values from the CIP/CUP era, particularly those for Tc-99, exceed the current TBD values derived from the 1990’s air sampling data by a couple 

orders of magnitude. In addition, separate higher values have been calculated for the oxide conversion plant based on the results of filter ash sampling mentioned 

on page 39 of the DOE Portsmouth Mass Balance Report (reference SRDB ID 10916). The facility-specific activity fractions for the assignment of recycled 

uranium contaminants are being revised where appropriate and incorporated into the Internal Dose TBD.

4 0015-5 Generic default value of 3.5%

enrichment for uranium is

inappropriate/claimant

Empirically derived yearly average

values for average specific activity for

monitored workers, as well as for

The default uranium enrichment of 3.5% in the Portsmouth 

TBD should provide a favorable mass to total uranium alpha 

conversion for a worker monitored only for exposure to 
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No. TBD Issue SC&A Draft Finding NIOSH Response

CLOSED unfavorable. specific job functions, suggest that

worker exposures involved high to

very highly enriched uranium, making

suspect the generic default assumption

of 3.5%.

depleted, normal, or low enriched uranium, but not higher

enriched uranium. However, gross alpha bioassay results are 

available until 1995, after which isotopic uranium results are 

available. Gross alpha (or isotopic U) would typically be

used for a dose reconstruction. Gross alpha urinalysis results 

eliminate the need to know the enrichment of the uranium. 

Doses are calculated from activity rather than mass, and the 

retention fractions and dose coefficients are similar enough 

for the uranium isotopes of interest that dose reconstructors 

assess all of them as U-234. 

SC&A Response (April 2011): More information needed. Are gross alpha bioassay results adequate for dose reconstruction such that they can substitute for 

the application of the generic default value of 3.5%, which NIOSH agrees does not apply to enrich uranium exposures?

July 2011 update: NIOSH further clarified its augmented matrix response at the July 6, 2011, Work Group meeting, noting that only gross alpha activity is used, 

obviating the need to know uranium enrichment. SC&A agrees and at the July 6, 2011, meeting, the Work Group closed the issue.

5 0015-5

CLOSED

TBD provides contradictory or

erroneous data and guidance

for MDC value.

Table 5.1.1-1 of TBD-5 identified that

for 1954-1995, the MDC for gross alpha 

counting was 10 dpm/liter; however, a 

minimum recorded concentration level 

of 50 dpm/liter is cited from GAT 

dosimetry documentation – a factor of 5

difference between the table value and

a site reference.

The 10 dpm/L value in Table 5.1.1-1 is equivalent to the 1 

dpm/100 ml typically seen in Portsmouth bioassay records. 

The source of the information stating bioassay results had a

reporting level of 50 dpm/L in the TBD Section 5.1.2.1 is 

incorrect, i.e., 50 dpm/L is not consistent with observed 

reporting level. This is pointed out in a rather vague manner 

in the last sentence of the first paragraph of that section; that 

wording will be changed to be more precise in the next TBD 

revision. However, the TBD does leave open the possibility 

that the reference may be correct (higher reporting level) for 

some data, and if a higher reporting level is found in a 

worker’s bioassay records it is incorporated as the limit of 

detection for that sample in dose assessments. No technical 

change is needed to the TBD because individual bioassay 

data are used.

SC&A Response (April 2011): Agree that “more precise wording” needs to be added in the next TBD revision.

July 2011 update: Work Group closed the issue at July 6, 2011 meeting.

6 0015-5 Mobile in-vivo chest counts Mobile In Vivo Radiation Monitoring The chest counting results from the MIVRML have limited 
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No. TBD Issue SC&A Draft Finding NIOSH Response

CLOSED

subject to significant

limitations and uncertainties.

Laboratory (MIVRML) chest counts

for the detection of uranium, TRUs,

and fission products are subject to

significant limitations and

uncertainties.

use, but are good for detection of U-235, as the finding 

mentioned, although total U (U-238 + U-235), depleted 

uranium (U-238), Tc-99, and Np-237 are also typically 

reported in MIVRML records. If U-235 can be quantified, 

then total U from a broad range of enrichments can be 

bounded based on the radioactivity ratio of U-235 to total U, 

which can be estimated for gaseous diffusion enriched 

uranium. 

Transuranics are present at the Portsmouth site only as 

contaminants in recycled uranium and as such are found in 

small quantities relative to uranium. Because of this, the in 

vivo results are not useful for determining intakes because 

the MDA is too large for detecting the small potential 

intakes. Ratios to uranium quantities are instead used for 

assigning intakes of transuranic radionuclides, as well as Tc99.

The primary use of a uranium chest count is for detecting the 

long term buildup of insoluble material in the lungs. As 

noted in the SC&A comments, U-235 activity is a small

fraction of even highly enriched uranium, with U-234 

activity always at much greater concentrations. 

Additionally, the U-238 MDA is quite large because it is 

monitored through its daughter rather than directly. Given 

these limitations, the uranium in vivo results are of limited 

usefulness to dose reconstruction; urine samples will be 

limiting in almost all cases and there have been no cases to 

date where an individual had only chest counts. Chest 

counts are reviewed by the dose reconstructor to determine if 

they provide any additional information. 

 

This information will be added to the site profile, and 

extraneous information (such as discussion of nuclides that 

are not monitored) will be removed.

SC&A Response (April 2011): More information needed. Will NIOSH revise current wording in TBD to indicate that only U-235 data from the
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No. TBD Issue SC&A Draft Finding NIOSH Response

MIVRML should be relied upon for the purpose stated in the response? 

July 2011 update: At the July 6, 2011, Work Group meeting, NIOSH committed to providing the additional direction indicated in its response in the next revision 

of the TBD. On that basis, the Work Group closed this issue.

7 0015-6 (Occupational

External Dose)

IN ABEYANCE

Assumed LOD for shallow

dose lacks technical support

and is not claimant favorable.

The assumed LOD value for shallow

dose (as defined by the two-element

film dosimeter used between 1954 and

1980) lacks technical support and is

not claimant favorable.

SRDB references 3782 and 8573. These references describe 

the ORNL coordinated effort to specify and procure the 4-

element combination security and personnel dosimeter used 

by Portsmouth, Paducah, Y-12, K-25 and ORNL. PORTS 

implemented the combination dosimeter August 1, 1960. 

Prior to August 1960, Portsmouth used a two-element film 

dosimeter likely of identical design to the one used at 

ORNL, Hanford, etc. Substantial documentation exists 

(SRDB 8573, 4793, 11296) regarding its capabilities. 

Several sites quote the MDL as 30 mrem (i.e, X-10, Y-12, 

Paducah, Fernald, etc.). The Site Profile will be revised to 

include the combination dosimeter information. 

SC&A Response (April 2011): Agree. NIOSH apparently agrees that more technical support information for the combination dosimeter is necessary and will 

revise the TBD accordingly.

July 2011 update: At the July 6, 2011, Work Group meeting, NIOSH noted that they were working on this issue with the likelihood that the LOD would need to 

be increased based on additional data (given that site went from a two to a four element dosimeter in 1960). The Work Group decided to hold this issue in 

abeyance. 

Updated DCAS Response: Portsmouth maintained onsite personnel dosimetry from 1954-1998. For the period 1954-1980, the LOD for photons and electrons is 30 

mrem as given by Table 6-3 in the Portsmouth External TBD (ORAUT-TKBS-0015-6) footnote c. The supporting reference for the information in Table 6-3 of 

the TBD is found in “Film Badge Procedure”, Goodyear Atomic Corporation, 1963, reference SRDB ID 8121. Further research identified supporting information 

for the electron LOD value in the ORNL External TBD (ORAUT-TKBS-0012-6), Section 6.5.2 and Table 6-24. The two-element film system used at ORNL also 

had a reported LOD value of 30 mrem that was applicable to photon and electron dose. Note that the two-element system was used at Portsmouth from 1954 up 

until the implementation of a multi-element TLD system on 1/1/1981 (ORAUT-TKBS-0015-6, Section 6.3.2.1). 

8 0015-6

IN ABEYANCE

Unmonitored shallow doses

derived from coworker data

suffer deficiencies likely

result of dosimeter design

limitations.

The non-penetrating (or beta)

component that would be expected to

have registered on the open window

portion of the film dosimeter was, on

average, essentially zero. With

presence of Tc-99, plus uranium

Tc-99 exposure, as discussed on p. 26 of ORAUT-TKBS0015-6, poses minimal external exposure potential because 

of limited range and the shielding afforded by clothing and 

gloves. Energy employee exposure situations that 

potentially involved Tc-99 skin contamination would be 

addressed using VARSKIN to assist with the skin dose 
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No. TBD Issue SC&A Draft Finding NIOSH Response

daughters, near absence of

measureable beta radiation up until

1980 unlikely. Another problem is

accountability for missing or

unmonitored exposures.

estimation.

Null values can result for coworker shallow dose due to 

subtraction (see page 8 of ORAUT-OTIB-0040). In these 

situations, dose to the skin is entered into IREP as 30–

250 keV photons (which has a higher POC effectiveness 

compared to >15 keV electrons). In addition, this quantity of 

30-250 keV photons contains missed dose as described in 

ORAUT-OTIB-0040 and ORAUT-OTIB-0020.

SC&A Response (April 2011): More information needed. How does Table 8-2 of OTIB-0040 correctly reflect the coworker shallow doses when shallow dose 

was not correctly determined until around 1987 (TBD-6, page 27)? This problem is illustrated by the coworker 50% dose levels showing mostly zeros until the 

mid 1980s.

July 2011 update: At the July 6, 2011, Work Group meeting, NIOSH/ORAUT further explained how null values can be generated in calculations; however 

missed photon dose added in at 50th and 95th percentile, which is claimant favorable. SC&A agreed with the explanation and the Work Group closed that portion 

of the issue, leaving in abeyance the issue that deals with Tc-99, which is the subject of a NIOSH review (see issue #9 below).

SC&A Response (October 2012): NIOSH provided ORAUT-RPRT-0059, External Exposure to Technetium-99 at the Gaseous Diffusion Plants, dated Feb. 7, 2012. 

SC&A subsequently recommended closure of this issue for the Paducah Gaseous Diffusion Plant, and likewise, recommends closure of the issue for the 

Portsmouth TBD.

9 0015-6

IN ABEYANCE

External exposures to

localized skin and to

extremities inadequately

monitored; guidance to dose

reconstructors too subjective.

Numerous activities at PORTS

subjected workers to external radiation

fields in which extremities would have

received substantially higher

exposures than shallow doses recorded

by personnel dosimeters. The TBD

provides several hypothetical

“examples,” including source term

models, that SC&A believes, as

guidance, are too subjective and

arbitrary.

When information is presented that indicates a skin 

contamination may have occurred, an evaluation is 

performed during dose reconstruction on a case by case basis 

using claimant records and claimant favorable methods 

described in project documents. In addition, modeling 

programs such as VARSKIN, Microshield, or ATILLA can 

be used to calculate a skin dose – including dose to the 

extremities. The TBD will be updated to include current 

references that are available to assist with the calculation of 

dose to the skin and extremities. These include DCAS-TIBs0010 and -0013, which provide guidance regarding 

geometric correction factors, and, in the case of TIB-0010, 

methods for calculating extremity dose using the results of 

ATILLA modeling. Also, OTIB-0017 will be included as a 
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No. TBD Issue SC&A Draft Finding NIOSH Response

reference for calculating dose to the skin from contamination 

and hot particle exposure scenarios. Further, the use of 

VARSKIN to calculate dose to the skin is discussed in 

OTIB- 0017.

SC&A Response (April 2011): Agree. Localized skin and geometry issues are addressed to some extent in the TBD and associated references to be

added; further development concerning this issue is most likely a global item.

July 2011 update: NIOSH agreed following discussions at the July 6, 2011, Work Group meeting that further review on its part is necessary for the broader 

question of how skin dose is addressed in the context of Tc-99 exposure at all three GDPs. The Work Group decided to hold this issue in abeyance. 

SC&A Response (October 2012): NIOSH provided ORAUT-RPRT-0059, External Exposure to Technetium-99 at the Gaseous Diffusion Plants, dated Feb. 7, 2012. 

SC&A subsequently recommended closure of this issue for the Paducah Gaseous Diffusion Plant, and likewise, recommends closure of the issue for the 

Portsmouth TBD.

10

neutron 

0015-6

CLOSED

Before 1992, PORTS failed

to monitor workers for neutron

exposures; current guidance

for unmonitored exposures

incomplete.

Dosimetry programs at PORTS from

1954 to 1992 failed to monitor workers 

using calibrated personnel neutron 

dosimeters. A Health Hazard

Evaluation (HHE) conducted by

NIOSH at PORTS in 1997 highlighted

the potential for increased production

of neutrons due to “slow cookers,”

i.e., subcritical neutron generation due to 

buildups of uranium in processing.

Although the TBD acknowledges the

HHE conclusions, it ignores the issue

of past unaccounted neutron doses

associated with slow cookers.

PORTS TBD revision dated August 20, 2007 does contain 

guidance for neutron dose reconstruction including for 

unmonitored exposures. SRDB 10913 describes a NIOSH

Health Hazards Evaluation during 1996 of PORTS worker 

exposure to neutron radiation including slow cookers. 

Workplace neutron dose and spectra measurements during 

1992 (SRDB 8119) do identify low-level neutron exposures 

rates below 1.0 mrem/hr at the respective measurement 

locations (X-7000 Radiation Calibrations, X-326 Assay 

Laboratory, and X-326 PW Vault). Dose reconstruction 

practices do include evaluation of potential neutron dose by 

reviewing the claim, CATI and exposure record 

documentation.

DCAS believes that the neutron doses in the cylinder yards 

are more significant/routine than neutron doses due to a 

buildup of material in processing systems. While it is 

understood that there was some buildup of material in the 

systems, DCAS is unaware of any significant deposits that 

would have routinely/ chronically caused significant 

subcritical multiplication. Therefore, the neutron dose rate 

in the cylinder yard should be considerably higher and the 
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No. TBD Issue SC&A Draft Finding NIOSH Response

neutron to photon ratio given by the TBD of (0.2) should 

provide a bounding and claimant favorable estimate of 

neutron dose especially when compared to the neutron to 

photon ratio estimated in SRDB 10913 of 0.125.

SC&A Response (April 2011): More information needed. How are “slow cooker” neutron doses included in the n/p value of 0.2 in Table 6-23

when this value was taken from a survey of cylinders at the Paducah GDP (p. 33 of Port GDP TBD-6)? Ref #10913, page 7, states that slow cooker

neutrons were not addressed in their evaluation. Ref #8119 is concerned with neutron energy spectra and dose rates, but does not address slow cooker

neutrons specifically.

July 2011 update: At the July 6, 2011, Work Group meeting, SC&A agreed with NIOSH that the referenced site-specific review was more speculative than factbased regarding the likelihood and significance of this phenomenon. The Work Group agreed to close this issue.

11 0015-4 (Occupational

Environmental Dose)

CLOSED

Use of generic ambient

environmental dose of 

35.9 mrem/y is too restrictive 

for non-compensable claims 

and claimant unfavorable.

SC&A disagrees with the implicit

assumption in the TBD that there were

not significant environmental releases

at PORTS that would give rise to

radiation dose rates above natural

background.

In Rev 1 (2006) and Rev 2 (2009) of the Environmental 

TBD, a maximum value of 44.8 mrem/2000 hrs (which is 

adjusted for 2600 hrs during DR) is recommended for 

workers in areas near Perimeter Road based upon the highest 

reading outside the DU cylinder storage. However, this 

value is only assigned if a more refined estimate is 

necessary. A maximizing dose of 0.452 rem/yr (which is 

derived from the 1987 result at monitoring location 874, 

adjusted for 2,600 hours exposure time and multiplied by an 

uncertainty factor of 1.3) is actually assigned during most 

dose reconstructions. Attachment B of ORAUT-PROC0060 “Occupational Onsite Ambient Dose Reconstruction 

for DOE Sites” lists maximizing ambient dose values for 

various sites, including Portsmouth, and provides the basis 

for those values.

SC&A Response (April 2011): More information needed. Agree conceptually, but cannot locate guidance regarding application of 0.452 rem/yr as

maximum dose for bounding environmental dose during dose reconstructions. If this is not in the TBD, it seemingly should be, for clarity sake.

July 2011 update: With NIOSH’s clarification, SC&A agreed with the response and the Work Group closed the issue.

12 0015-4

CLOSED

Default ambient

environmental dose of 

267 mrem/y to workers 

Table 4.3.1-1 of TBD-4 identifies the

origin of the 267 mrem/y value as that 

corresponding to location 874 for the 

In Rev. 2 of TBD-4, the 267 mrem/2,000 hr yr for location 

874 for the year 1987 is now in Table 4-6 and the value of 

178 mrem/2,000 hr yr for location X-745E for the year 2000 
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No. TBD Issue SC&A Draft Finding NIOSH Response

exposed at Cylinder Storage 

Yards is without technical 

basis and may be too low.

year 1989; and Table 4.3-3 of TBD-4 

identifies the value 178 mrem/y as the 

average deep dose for location X-745E 

(depleted uranium cylinder storage yard) 

for the year 2000. It is difficult to match 

and rationalize these two independent 

measurements based on facts presented 

by SC&A.

is now in Table 4-5. The 178 mrem/2,000 hr yr does not 

represent only neutron exposure because these TLDs were 

calibrated for both Gamma and neutrons. The TBD 

discussed the assumption that the portion of the 267 mrem/yr 

in 1987 could be attributed to neutron exposure of 

178 mrem/yr, not that it should be additive.

SC&A Response (April 2011): Agree.

July 2011 update: Working Group closed issue.

13 0015-4

CLOSED

Ambient environmental doses

are confined to deep dose that

may significantly

underestimate potential

shallow dose to skin.

Claims involving skin cancer, as well as 

other surficial tissues, must be evaluated 

on the basis of shallow dose estimates. 

Dose estimates involving external 

ambient environmental doses are 

restricted to the deep dose, which may 

significantly underestimate the shallow 

dose.

Due to the nature of non-penetrating dose, it would not be 

expected to see elevated levels compared to the penetrating 

dose for areas where environmental doses apply. ORAUTOTIB-0017 is the approved document for addressing the 

assignment of shallow dose.

SC&A Response (April 2011): Agree.

July 2011 update: Working Group closed issue.

14 0015-3 (Occupational

Medical Dose)

CLOSED

TBD identifies two 

timeframes for

photofluorography (1954– 

1960 and 1954–1957); the

shorter period was selected

and based on single record.

A time period for PFG is restricted to

1954 to 1957, despite statements in

the TBD verifying extended PFG use

at PORTS from 1954 through 1960.

The TBD will be revised for consistency and to clarify 

guidance regarding which years to assign PFGs. We have 

completed 1,119 Portsmouth cases and while we have seen 

several PFGs performed between 1954 and 1957, we have 

not seen evidence of PFG X-rays beyond 1957.

SC&A Response (April 2011): Agree that “the TBD does need clarification and consistency regarding PFGs;” this wording suggests that the next

version of the TBD will be revised accordingly.

July 2011 update: The Work Group closed the issue with the understanding that dates will be clarified.